Contributing Firms:
The much anticipated participation exemption regime for dividends was confirmed in the Budget with it set to come into effect from 1st January and is held up as highlight from Budget 2025 for increasing Ireland’s attractiveness for international business.
In this Special Budget 2025 Edition of the Irish Tax Monitor contributors were asked to give the main points from their firm’s pre-Budget observations under the following headings: Investment Funds; Housing; SMEs/Private Business; Tax Simplification; FDI & Financial Services and any other business. The Department of Finance’s second feedback statement on the Participation Exemption also features.
What are the takeaways from Budget 2025 for Ireland’s competitiveness as a location for international business, and can you comment on the principal business impacts, including any proposals regarding tax administration and simplification in the Budget?
The Tax Appeals Commission made its first determination in relation to transfer pricing in its determination 59TACD2024. The case involved a multinational granting share options to employees of an Irish subsidiary and such transactions’ transfer pricing implications. What are the key points from the determination for multinational companies?
With the Court of Justice of the European Union passing its judgement in the Apple State aid case in favour of the European Commission the case is now closed. Many commentators have expressed surprise at the CJEU judgment. What is your view on the outcome of the case? and given the case’s international significance what does it mean for Ireland’s standing as a location for multinational businesses?
The OECD has introduced updated CRS schema and a new framework for Crypto-Asset Reporting. Can you please outline the changes?
The Revenue Commissioners has recently published guidance on the administration of BEPS Pillar 2. Can you outline the key takeaways on the operation of Pillar 2 for large Multinational and domestic groups in scope of the rule?
Can you comment on noteworthy determinations from the Tax Appeals Commission from the first half of 2024?
Budget 2025: What are the takeaways from Budget 2025 for Ireland’s competitiveness as a location for international business, and can you comment on the principal business impacts, including any proposals regarding tax administration and simplification in the Budget?
Transfer Pricing: The Tax Appeals Commission made its first determination in relation to transfer pricing in its determination 59TACD2024. The case involved a multinational granting share options to employees of an Irish subsidiary and such transactions’ transfer pricing implications. What are the key points from the determination for multinational companies?
Apple state aid case: With the Court of Justice of the European Union passing its judgement in the Apple State aid case in favour of the European Commission the case is now closed. Many commentators have expressed surprise at the CJEU judgment. What is your view on the outcome of the case? and given the case’s international significance what does it mean for Ireland’s standing as a location for multinational businesses?
Crypto Assets: The OECD has introduced updated CRS schema and a new framework for Crypto-Asset Reporting. Can you please outline the changes?
BEPS Pillar Two: The Revenue Commissioners has recently published guidance on the administration of BEPS Pillar 2. Can you outline the key takeaways on the operation of Pillar 2 for large Multinational and domestic groups in scope of the rule?
Tax Appeals Commission: Can you comment on noteworthy determinations from the Tax Appeals Commission from the first half of 2024?